ML20082F793

Addl Discovery Responses on Contention 8F1 Re Direct Emissions from coal-burning Power Plants.Certificate of Svc & Negotiations Encl

ML20082F793
Person / Time
Site:	Harris
Issue date:	11/22/1983
From:	Eddleman W EDDLEMAN, W.
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ML20082F772	List: ML20082F768 ML20082F787 ML20082F793
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NUDOCS 8311290249
Download: ML20082F793 (8)

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ADDITIONAL DISCOVERY 9ESPONSES b h b ON CONTENTION 8F1 8F1-21. According to Figure 4-2, p. 99, of Michael D. Yokell's Environmental Costs and Benefits of Solar Energy (1980), which treats the health effects of particulates extensively, the direct emissions from coal-burning power niants are about 04 nounds per million RTU delivered. Assuming conversion efficienev of 33 1/3 nercent (10,238 BTU /kWh), which is about the national average heat rate for coal-fired plants, and also close to CP&L's average heat rate for coal nlants, that is about /MBTU at the source. If we take the Table S-3 45 MWe coal-fired plant to be running at 100% canacity factor (conservative, since the emissions ner MBTU inout would be higher if the 115h metric tons of Table S-3 are spread over fewer kWh at any lower capacity factor), in a year it generates 39h,200 M*m.

One metric ton is 220h lbs, so the 1154 -etric tons of narticulates, from Table S-3, is 2,5h3,h16 pounds. The 39h,200 M'E at 10,238 BTU /kWh gives about 4 036,000 MBTU. This isGMt pbove 0.6 lbs/MBTU.

Thus, if we take the Yoke 11 data on health effects, at conservative assumotions (neglect conversion loss in Yoke 11 table, and assume 100%

a capacity factor for the Table S-3 coal plant), we have comparable health effects ner M'E for the Yoke 11 estinaten and Table S-3 coal niant, since the particulate emissions from both are about 0.6 lb/MBTU under these assunntions.

Taking then Yoke 11's Table h-12 (25 years ) Cumulative Exnected Damages and Benefits, electric utility particulate natter does about

$75 billion of damages in 25 years (value of human life in this table is $200,000), all in 1972 do11ers. That 's abo ut $3 billion 10 g A 1972 dollars ner year. From Tables h-8, h-9 and 4-1R %e]4can){ infer

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that a $100,000 increase in the value of a human life increases ,

.q-C % $ M u A the electric utility damages (25 years ) about Q50 billion,, thus giving a total livas lost (25 years) of about 3.5 nillion.

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That is 140,000 lives per year lost, total, due to electric utility operations. Coal (see pp 50-52, ibid) is about half of total electric utility energy innuts, i.e. about 25 cuads ner year.

This is 25 x 1015 BTU. Suecifically, the base case is 26.6 quads per year of coal, the maximum paractical case is 25.1 quads of coal a year, and the maximun feasible case is 2h.9. Particulate damages decline with these (see Table h-12, D.78) from 75.6 Bia11on 8 (1972) to 74.4 to 73 3, but these are 25-year damage totals and thus not directly connarable to year-2000 uses. If all of the particulate damage were due to coal (maxinun case under Yoke 11's granhs and tables), the 25 quads of coal ner year (a high value) would cause the loss of 1500011ves a year due to particulates.

Now recall that our 45-MW-e Table S-3 x coal plant uses about 14 trillion BTU per year at 100% CF. Over a Harris operating life of 25 years, that is 100 trillion BTU (ner Harris unit) if the coal plant is at 100% CF. Coal power for uranium enrichment would in fact come at a very high canacity factor (the load factor for a flat-out onerating enrichment olant is near 100%,

and *3ually over 90%). So this assunntion is realistic.

Taking 80% CF to be conservative, the S-3 coal ulant still produces particulates equivalent to those from 80 trillion BTU (at a mininum) omf coal burning over the liafe of a Harris unit.

! lost Since 15000 lives (at most) corresnond to 25000 trillion BTU (25 cuads) of coal burned, via particulates, we can calculate the loss of life (per Harris unit) from the Table S-3 coal ulants can 0

be as high as x 15000, or h8 lives. We can also 25000 1ciok at the environmental damages: $3 billion ner quad over 25 years (at minimum, since this takes a year-2000 figee for coal consuned and divides it into a 25-year total of danages including years

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in which less than 25 quads of coal are burned), fron navticulates.

Since the Harris plant lifetime is also 25 years, the damages from the S-3 coal plants (and this is directly fron Yokell's numbers for damages, whereas the lives lost are calculated under assumptions) are the ratio of quads they consune yearly, 1 250 to one quad. They consume at nost h trillion BTU (1 1RRR of a quad) per year (at 100% CF), but their coal nellutant outnut corresponds (see p.1 of this resnonse) to 4 trillion BTU from coal burned at Yoke 11's calculated or nodeled outnut Der BTU of narticulates.

Thus, the 25-year damages fron S-3 coal niants is (uer Harris unit)

$3 billion over 250, or $12 nillion per unit.

While this doesn't break out damages by disease as you request, I still haven't calculated that. But this does give an estimate that up to 96 deaths could be caused just by Table S-3 coal particulates associated with 2 Harris units over a 25-year onerating life. Since the FES (and Fabrikant affidavit of Anplicants) claim nuclear emissions from Harris will only cause about 2 deaths over each unit's life, these coal-caused deaths associated with Harris are significant.

8F1-24. Yes. I have copied the book by Yoke 11, Environmental Benefits and Costs of Solar Energy, which gives detailed estimates of dollar costs corresnonding to deaths a due to air pollution, e.g. coal particulates. See above resnonse for more details. See, e.g., pp 36-38 thereof re sources of its estinates of damages and health e*fects. I an giving Hill Carrow a cony of this book (x-roxed) to keen.

8F1-3(a), Although I do not " contend" this , it is true (see nage 1 above, that the Table S-3 ulant's emissions are about 0.6 nounds per million BTU at the lonwest estimate calculated by ne.

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If you consider the variance required for CP&L's Foxboro 3 coal plant in 1979, and the data filed with the NC Division of Environmental Management in the 1982-83 coal narticulate rulemaking, you will see that emissions at this level will likely violate the ambient air quality standards if a real power plant enits then. (b) Hynothetical plants have no emissions, but a real nlant which would, would.

See the 1st page of this resnonse for calculations, and see the above-referenced records, which CP&L nossecses, for details.

8F1-6. The Yoke 11 document referenced in response to 8F1-2h above includes such estinates, as do its sources.

8F1-7(a) I have received the Yoke 11 document. It was filed under solar energy and I noticed it when a stack of doctinents fell over. In perusing it, I checked the index re narticulates and found the information relevant to this question. Per agreement between me and Apolicar.Ls ' counsel Hill Carrow, I have not nade an extensive search for such information in my non= coal files, but only nade availabic that located readily. (b) see (a ) .

8F1-10(b): The facts made available by Yoke 11, and those computed therefron by me on nages 1 thru 3 above, should be included in a cost-benefit analysis for Harris.

8F1-11: The Yoke 11 book may nake such a comnarison.

There are also studies (e.g. that in Science some years ago, connarinr; actual coal emissions of radioactive naterials, to radioactive emissions from new, much-lower enitting nuclear plants)

I know of.

8F1-12. Yoke 11 book is the only one I have a cite on.

I don't recall the date of the Science article, but since coal plants emit radioactive material as narticulates (e.g. uraniun and thorium), it would be relevant to this contention.

\,. ..

-5 8F1-2. By agreement with Annlicants ' counsel Carrow, I am making available to him for insnection and conying 11-28-83 the following documents which suonort the idea that the Clean Air Act regulatory staructure (e.g. EEA ) is inadequate to protect the public health and safety: Sierra November / December 1983 nages 58-59 (re excess cancers 3/100 norsons exnosed, to be allowed from Uranium mill tailings); Inhalable Particulate Matter (NC Dent of Natural Resources and Connunity Develonnent, Jann 1K983);

p.76 of Health Effects of Environmental Pollutants, Fig 6-18, Main targets of major air pollutants; Natural 9esources Defense Council Report from the Chairman 1982/83, pages 17-19 (suits against EPA to make it enforce the law on cancer-causing air pollutants); National Clean Air Coalition, October 1983 undate, 11% to 21% of current lung cancer cases could be rrevented by better control of air nollution; State of the Environnent 1982, renort of the Conservation Foundation, already cited; Raleigh News & Observer 9/18/83 page 3A, already cited, re arsenic and uranium-caused deaths EPA nronoses to allow.

Coal deaths per year (8F1-k?) 15000 ner yea", Desrxirable Particles p.1, footnote citing un to 100,000 ner year. This document has already been nade available to you. See Lave & Seskin,

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1979, American Shcentist 67:178.

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8F1-2. By agreement with Apolicants' counsel Carrow, I am making available to him for insnection and conying 11-28-83 the following documents which suonort the idea that the Clean Air Act regulatory staructure (e.g. EPA ) is inadequate to protect the public health and safety: Sierra Novenber/ December 1983 pages 58-59 (re excess cancers 3/100 nersons exnosed, to be allowed from Uranium mill tailings); Inhalable Particulate Matter (NC Dent of Natural Resources and Connunity Develonnent, Jann 1N983);

p.76 of Health Effects of Environmental Pollutants, Fig 6-18, Main targets of major air pollutants; Natural 9esources Defense Council Report from the Chairman 1982/83, pages 17-19 (suits against EPA to make it enforce the law on cancer-causing air pollutants); National Clean Air Coalition, October 1983 undate, 11% to 21% of current lung cancer cases could be prevented by better control of air pollution; State of the Environnent 1982, renort of the Conservation Foundation, already cited; Raleigh News & Observer 9/18/83 page 3A, already cited, re arsenic and uraniun-caused deaths $PA pronoses to allow.

Coal deaths per year (8F1-h?) 15000 ner yea", nestr.irable Particles p.1, footnote citing un to 100,000 ner year. This document has already been made available to you. See Lave & Seskin, 1979,AmericanShntist67:178. ,

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UNITED STATES OF AMERICA NUCLIAR REGUIATORY COINISSION

) Dockets 50-400 In the matter of CAROLLNA POWER k LIGHT Co. Et al. ) and 50E01 0.L.

Shearon Harris Nuclear Power Plant. Units 1 and 2 CERTIFICATE 0F SERVICE I hereby certify that copies of Additional Discoverv Mesponses on Tnte-vennwe 8F1, and of WE_ Resnonse to S aff on 37B and of Joint Mesncnse to starr on Joint II day of Novenber 1981 , by deposit in HAVE been served this 22 the US Mail, first-class postage prepaid, upon all parties whose names are listed below, except those wnose nanes are rarked with an asterisk, for whom service was accomplished by *only Judge cony of Yokell book to Bawth Asihce llev and CA Barth for NRC Staff Staff has particulates under review now.

Note that WtE37B resnonse is on back of Joint Intervenor resn p.3

• Judges James Kelley, Glenn Bright and Janas Carpenter (1 egy each)

Atomic Safety and Licensing Board US Nuclear Regulatory Commission Washington DC 2o555 George F. Trowbridge (attorney for Applicants) R.uthanne G. Miller Shaw, Pittman, Potts & Trowbridge ASLB Panel 1800 M St. NW USNRC Washington DC 2055 5 WashinEton, DC 20036

• 0ffice of the Executive Legal Director Phyllis Lotchin, Ph.D.

105 Bridle Run Attn Dockets 50-400/401 0.L. Chanel Hill NC 2751h USNRC Washington DC 2o555 Dan Read Docketing and Service Section[3K) CEAM/ELP sox 52h Attn Dockets 50-hoo/hol o.L. Chapel Hill NC 2751h Office of the Secretary USNRC Wasuington DC 20555 nedert eruhar, Exec. Dir.

T Hill Carrow Public Staff,Agx 991 John Runkle CP&L Raleigh, MC 27602 CCNC Box 1551 Raleigh NC 27602 .

3o7 Granville Rd *Bradley W. Jones Chapel Hill Nc 2751k Ok9

.P d s USNRC Region II 101 Marietta St.

'Travi s Payne Edelstein & Payne fW Orril Atlanta GA 30303 Mox 12601 VT6 C' fvg<w '%t 0

Raleigh WC 276o5 II3 uWCertified by h Richard Wilson, M.D.

729 Hunter St.

Apex MC 27502

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